Deemed Dividends Without Cash—New IRS Proposed Code Sec. 305(c) Regs Trigger Outcry and Create Challenges for Convertible Debt, Stock and Rights | Wolters Kluwer Financial Services
  • Insights

  • Deemed Dividends Without Cash—New IRS Proposed Code Sec. 305(c) Regs Trigger Outcry and Create Challenges for Convertible Debt, Stock and Rights

    by Stevie D. Conlon

    Published November 30, 2016

    For financial industry participants that had advocated that the IRS exempt conversion ratio adjustments from deemed dividend treatment, the Proposed 305(c) regulations are distressing and there are continued requests and comments that the rules be withdrawn or that the rules should not apply to convertible bonds and stock. In this article, Stevie Conlon examines the issues that must be resolved before final regulations are issued.

    Download the PDF to read the entire article.


  • Please take a moment and tell us what you think of our content.